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City of Mill Valley

The Mill Valley City Council must honor the approved Miller Avenue Streetscape Plan

The following is a comment letter sent to the Mill Valley City Council, explaining why they must reject the proposal to reduce traffic lane capacity by 50% in the Parkway section of Miller Avenue. This letter is in addition to our letter submitted on August 6, 2017, which is attached below.

The original petition opposing this plan has gathered over 500 Mill Valley resident's signatures but it was ignored by the City Council. If you agree that the City should honor the approved plan and keep Miller Avenue two lanes in each direction, please let the City know by signing the new community petition - CLICK HERE


Dear Mill Valley City Council:

The City Council is being asked to consider approving a reduction in the number of vehicle travel lanes in the Parkway section of Miller Avenue. As I’ve noted previously, I am opposed to any reduction in vehicle lanes and I would like to add the following comments into the record.

The public process that resulted in the Miller Avenue Streetscape Plan spanned a 15-year period starting in January of 2000 and continuing through the end of 2015. As explained in great detail in the November 2015 public presentation of the Plan[1], the process was exhaustive. Every aspect of the Plan was rigorously debated, examined and finally agreed upon, resulting in what our town could honestly call a “best efforts” compromise solution.

Under the section of the final Plan called “Project Goals,” the very first goal is to “improve multimodal circulation, access and safety.” Traffic flow would be the number one aspect of any “circulation” improvement, since traffic congestion is the number one complaint in Mill Valley. Therefore, anything that might increase traffic congestion should be considered a non-starter. In addition, a reduction to single lanes of traffic has the potential to reduce public safety, as noted in the Staff Report.

The Staff Report rationalizes the proposal to cut traffic capacity by 50% by stating that

…the one lane configuration has been operating for approximately one year without traffic congestion, the City has received public interest to maintain the one lane configuration.

The Staff Report further misconstrues past events when it states that

In 2008, the Miller Avenue Streetscape Task Force reviewed the one lane option in the Parkway, and recommended to initially retain two lanes but to consider the one lane option if funds become available and Council "deem it advisable".

The Staff Report gives the erroneous impression that consideration of the one lane option is still something the City Council can do if they “deem it advisable.” However, that is incorrect. That option was only available prior to the approval of the final plan and the adoption of the final Mitigated Negative Declaration in 2015. As explained further below, the City Council no longer has the discretion the staff claims.

The Staff Report also refers to “Average Daily Traffic Volumes,” but fails to provide any details regarding such data or to fully clarify to the City Council that any traffic counts done under present conditions are of zero predictive value.

We are currently inundated with notices, emails and social media alerts, almost daily, advising us to avoid Miller Avenue due to delays, pipes breaking, closures and any number of other issues. Traffic flows during this construction project have not been normal.

In addition, the approved streetscape design was intended to increase vehicular traffic once completed. That must be taken into account in any discussion of reduction of traffic capacity.

The City Council is now being guided to arbitrarily consider reducing the traffic lane capacity in the Miller Avenue Parkway area, by 50%, based on nothing more than anecdotal comments by an absurdly small number of residents and business owners, compared to the community input by hundreds of individuals and planning professionals, that resulted in the approved Plan and adoption of the Mitigated Negative Declaration California Environmental Quality Act (CEQA) document.

Finally, any changes to the approved Miller Avenue Streetscape Plan would not only require an amendment to the Master Plan, but would have to address a number of CEQA requirements as well.

CEQA Requirements

The approved Miller Avenue Streetscape Plan rests on the findings of the CEQA process that was conducted in 2014-2015, and the resultant Miller Revised Draft Initial Study: Mitigated Negative Declaration (09/17/15)[2]. As such, those finding were based traffic studies and projections with the goal and premise that the plan

…would enhance traffic circulation in order to accommodate existing and future traffic levels. [Emphasis added][3]

In fact, it was widely acknowledged throughout the Streetscape design process that one of the fundamental goals and hoped for outcomes of the project was to emphasize the importance of Miller Avenue as the main thoroughfare to and from downtown, and that it should be designed in such a way as to encourage its use (vs. discourage its use) by motorists over alternative routes, such as on Blithedale Avenue or by cutting through the narrow streets of the Triangle Neighborhoods (Tam Park and Sycamore Park). Cut-through traffic in particular, has historically been a chronic problem that the Plan promised to finally help mitigate.

At the risk of exacerbating this one impact alone, the suggestion to reduce lane capacity in the Parkway by 50% should be dismissed out of hand.

In any event, all the planning and traffic decisions approved by the City Council were incorporated into the CEQA review process and were based on these goals and assumptions not just about present use but also about future use and future traffic loads.

Yet, the City Council is now being guided by Planning Staff to arbitrarily consider making a significant change to the traffic plan in the Miller Avenue Parkway area, based on nothing more than anecdotal comments by a relatively small number of residents and business owners.

This makes no sense. However, it also puts the City in a Catch-22.

Changes to the Miller Avenue Streetscape Plan must address CEQA

As noted above, the Miller Avenue Streetscape Plan and the City’s ability to proceed with its renovation are based on the CEQA process that was undertaken in 2014 and 2015. Since the outcomes of that process and the resultant Mitigated Negative Declaration specifically included the provision that the Parkway be a total of 4 lanes for motor vehicle traffic (two in each direction), at this time the City cannot consider any proposed reduction in lanes without additional CEQA compliance.

This would include fully assessing the potential for significant unmitigated traffic impacts caused by such a change.

This assessment would therefore have to include a new traffic study and impacts analysis, making public notice of its findings and inviting public comment on those findings, through a publicly noticed comment period, prior to the discussion or approval of any such change. This new study would have to rely on newly collected data on existing traffic loads under normal operating conditions.

However, since we all acknowledge that current traffic loads and use patterns on Miller Avenue, and consequently all the other streets in the surrounding areas, are anything but normal at the present time, there is no way to actually do the required assessment at this time.

Similarly, doing a “pilot project” as proposed by Staff would certainly produce distorted and ultimately meaningless results, which cannot substitute for an actual traffic impact assessment once the street is operating at full capacity.

In sum, the City’s only legitimate option is to faithfully execute the Streetscape Plan as designed and allow new traffic loads and use patterns to emerge and normalize, before entertaining any roadway design changes or assessing their potential for significant impacts.

The changes to the Miller Avenue roadway are extremely complex and each change may have unpredictable traffic impacts in concert with all the other new features. The Streetscape Plan’s planning process did the best it could to analyze and understand these inter-related impacts. However, in many ways, we will have to wait and see how the new street works before we can say what, if any, changes might be recommended.

For the reasons noted herein, I ask that you reject any consideration of the reduction of traffic lanes in the Parkway.

Thank you for your time and consideration.

Respectfully submitted,

Bob Silvestri



[1] http://www.cityofmillvalley.org/civicax/filebank/b...

[2] http://www.cityofmillvalley.org/civicax/filebank/b...

[3] CEQA\Miller_Revised Draft IS_MND_v2.docx (09/17/15), page 137; Potentially Significant Unless Mitigation Incorporated